Food and beverage
Cocoa, coffee, soy and palm oil appear in thousands of products and blends. The hard part is linking the finished product to each supplier's or cooperative's batches and plots.
EUDR · Regulation (EU) 2023/1115 · Applies 30 Dec 2026
EUDR: get your suppliers' data in one place before 30 December
The EUDR makes you prove, product by product, where each raw material comes from and that it was not grown on land deforested after 2020. With Dcycle you send the questionnaire to all your suppliers at once, they answer and upload their documents in a free portal, and you see who has replied and who has not. Dcycle's expert team supports you through the due diligence.
- Questionnaire to every supplier in one click
- Free portal for the supplier
- Status of every response
- Expert team for due diligence
GDPR compliant. Your data stays in Europe.
2,000+ companies already manage their ESG data with Dcycle
What you are asked for
Who asks you for EUDR data and where it gets stuck
The regulation asks for five data points per batch: HS code and quantity, plot geolocation, country, production date and proof of legality. Your supplier holds almost all of them, not you.
Procurement Collect the five data points from every supplier of cattle, cocoa, coffee, palm oil, rubber, soy or wood. Hundreds of emails, a different Excel template per supplier and nobody knows who has replied. One questionnaire sent to everyone at once, with each supplier's status in view.
Supplier at origin Answer several European customers, each with its own format. Takes weeks or never replies. A free portal, no licence needed, where they answer and upload their certificates.
Quality and compliance Have the evidence together before declaring. Documents are scattered across attachments, shared folders and the ERP. Every supplier's responses in one project, with contact and date sent.
Downstream customer The reference number of your declaration. There is no field to store it, so it gets lost between orders. Dcycle's team defines with you where each number is kept, and for five years.
Competent authority in a check Your scope matrix, your procedure and the evidence behind your risk assessment. It is rebuilt by hand weeks later. What you asked, to whom and when they replied, recorded from the first send.
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Product
What Dcycle does in your EUDR due diligence
Suppliers
You send the questionnaire to all your suppliers at once
You import your supplier list, click "Send to N not sent", confirm, and each supplier gets an invitation email. They answer in Dcycle's supplier portal, which is free and needs no licence, and upload their certificates there too. You see how many are not sent, pending, responded or expired, and who you need to chase.
- Import suppliers or add them one by one
- Bulk send with confirmation and failed-send count
- Filters by status and search by supplier
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Summary
The EUDR in six facts
- 30 Dec 2026
Application date
Medium and large companies. Also micro and small companies in the timber sector.
- 30 Jun 2027
Second date
All other micro and small enterprises.
- 7
Commodities
Cattle, cocoa, coffee, oil palm, rubber, soy and wood. Unchanged since 2023.
- 31 Dec 2020
Cut-off date
Anything produced on land deforested after that date is non-compliant.
- 4%
Minimum fine
At least 4% of annual EU turnover, plus confiscation and exclusion from public contracts (Art. 25).
- −75%
Compliance cost
From about €8.1bn to about €2bn a year, estimated after simplification (COM(2026) 191 final).
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Timeline
The EUDR timeline
It was postponed twice, in 2024 and 2025, with the information system unfinished. In 2026 the system reopened at the end of June and the guidance was adopted on 13 July: the date to plan against is 30 December 2026.
| Date | Milestone | What it means |
|---|---|---|
| 29 Jun 2023 | Entry into force | Regulation (EU) 2023/1115 |
| 30 Dec 2024 | First date, postponed | Never applied |
| 30 Dec 2025 | Second date, postponed | Regulation (EU) 2025/2650: creates the downstream operator |
| 4 May 2026 | Simplification | Report COM(2026) 191 final, guidance and draft Annex I |
| 13 Jul 2026 | Acts adopted | Delegated act on Annex I and information system rules |
| 30 Dec 2026 | Application | Medium and large, plus micro and small in timber. EUTR repealed |
| 30 Jun 2027 | Micro and small | All other sectors, with a simplified declaration |
| 30 Dec 2027 | New products | Instant coffee, palm derivatives and other Annex I codes |
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Scope
Does the EUDR apply to you? Five questions
Answer them per product line, not per company: the same business is often an operator for some lines and a downstream operator for others. Keep your reasoning in writing, dated: an inspection asks how you reached your role.
- 1Does your product contain, was it fed with or made using any of the seven commodities?If not, you are out. If yes, carry on: the soy feed given to an animal counts.
- 2Is its HS code in the current Annex I?Use Annex I after the 13 July 2026 delegated act, not 2024 lists. Out: bovine hides and leather, retreaded tyres, soy for sowing and printed products in chapter 49.
- 3Do you place it on the EU market, make it available within the EU or export it?Exports are covered too. It is the most common scope mistake.
- 4Are you the first to place it on the EU market?If you import from a third country or export, you are an operator: full due diligence and your own declaration. If you process a product already declared, downstream operator. If you only distribute it, trader.
- 5What size is your company and which sector is it in?Medium or large, or micro and small in timber: from 30 December 2026. Other micro and small: from 30 June 2027, with a simplified declaration.
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Who does what
The four EUDR roles
The December 2025 reform concentrated due diligence in the first link and created the downstream operator. If you are a downstream operator, your job is not geolocating plots: it is collecting, filing and passing on reference numbers for five years.
| Role | Due diligence | Declaration | From |
|---|---|---|---|
| Primary operator (medium or large) | Full: information, risk assessment and risk mitigation | Own DDS before placing on the market or exporting, with the estimated annual quantity | 30 Dec 2026 |
| Primary operator (micro or small) | Full, with lighter documentation duties | Simplified declaration | 30 Jun 2027 (timber: 30 Dec 2026) |
| Downstream operator | Does not repeat the first link's | No own DDS: collects, keeps and passes on the reference number of the initial declaration | 30 Dec 2026 |
| Trader | Not applicable as such | Documentation duties; non-SME traders no longer submit a DDS in most cases | 30 Dec 2026 |
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Sectors
Who the EUDR affects in practice
The obligation depends on the product and your role in the chain, not your sector. These are the data points that usually block each one.
Retail and private label
Direct imports turn many retailers into operators. You need to know which catalogue lines are covered and who answers for each one.
Automotive and rubber
Tyres and natural rubber parts cross several supplier tiers. Traceability has to reach the country and area of production.
Wood, paper and packaging
The move from the EUTR adds geolocation and wider coverage. Micro and small timber companies also face 30 December 2026.
Importers and exporters
Whoever imports or exports a covered product must confirm their role and have the declaration submitted before the shipment.
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Annex I · 13 July 2026
What changed in Annex I
If your last scope review dates from 2024 or 2025, your list is wrong in both directions. The delegated act goes through a two-month scrutiny period of Parliament and Council, extendable, in which they can only veto it: work with these codes now and confirm the version published in the Official Journal.
Out of scope
Bovine hides and leather (4101, 4104, 4107)
Good news for footwear and leather goods, which leave the perimeter this way.
Retreaded tyres
All other tyres and rubber components stay in.
Soy for sowing
Soy for feed and processing does not change.
Printed products (chapter 49)
Books, newspapers and pictures already left with the December 2025 reform.
In scope from 30 December 2027
Instant coffee
Hits roasters and coffee distribution directly.
Palm oil derivatives
Food and cosmetics: check the technical sheets of your formulations, not just crude oil.
Frozen bovine tongues
An example of why scope is checked by HS code, not by product family.
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Country risk
Low risk does not mean exempt
Commission classification of 22 May 2025, under review in 2026 with new FAO data. Authorities must check 9% of operators with products from high-risk countries every year, and 3% for standard risk.
| Classification | Countries | What you have to do |
|---|---|---|
| High risk | 4: Belarus, Myanmar, North Korea and Russia | Full due diligence and enhanced checks |
| Standard risk | About 50, including Brazil, Indonesia and Malaysia | Full due diligence: information, assessment and mitigation |
| Low risk | The remaining 140 or so | Geolocation, proof of legality and declaration. No formal assessment or mitigation unless there are signs of non-compliance |
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The procedure
Due diligence in three steps
No shortcuts: without geolocation there is no risk assessment, and without negligible risk there is no declaration. The step that breaks schedules is step 1: gathering coordinates for thousands of plots takes months.
1. Information gathering
Per product and per batch, not per supplier: description, HS code and quantity; plot geolocation (polygon above 4 ha); country; date or period of production; and proof of legality at origin. Since 2026 the declaration also includes the estimated annual quantity.
2. Risk assessment
Cross the country or region classification, the presence of forests and indigenous peoples, the complexity of the chain and the degree of mixing, and the reliability of the information received.
3. Risk mitigation
Extra information or an audit at origin, supplier support, stronger traceability or a change of supplier if the risk cannot be closed. The system is reviewed every year.
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Enforcement
Who enforces the EUDR and what the sanctions are
Each member state designates its competent authority. Customs and market surveillance bodies run much of the checks on the ground.
Competent authority
Each member state designates the authority that applies and enforces the regulation and inspects operators and traders.
Coordination between authorities
Customs and market surveillance bodies coordinate the checks carried out at the border and on the market.
Commission information system
Declarations and reference numbers are filed in the Commission's information system, which national authorities can access.
EUTR transitional regime
The EUTR is repealed on 30 December 2026 but keeps applying until 31 December 2029 to wood produced before 29 June 2023.
Sanctions (Art. 25)
| Sanction | Scope |
|---|---|
| Fine | At least 4% of the company's annual turnover in the EU |
| Confiscation | Of the products concerned and the revenue earned from them |
| Exclusion | From public procurement and access to public funding |
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Work plan
The plan, in the order that matters
With time, it is 20 weeks. If you start in the autumn, the order is the same: prioritise products by volume and keep the last two weeks of December free, when neither the system nor your suppliers run at full speed.
| Block | What gets done | Who | Deliverable |
|---|---|---|---|
| Owner | One person with ERP access and the authority to block a purchase. Without that name, the plan does not start. | Management | Appointment record |
| Inventory | Pull everything you buy, sell and export from the ERP and match it against the current Annex I by HS code. | Procurement and IT | Scope matrix |
| Roles | Per business line: operator, downstream operator or trader. One company can hold several. | Compliance and management | Role map |
| Suppliers | Request for the five data points, weekly follow-up and escalation. The longest and most underestimated block. | Procurement | Response log |
| Information system | User set-up, test declarations and the choice between web interface or API. | Compliance and IT | Test report |
| Close-out | Files per product family, internal training and a blocking rule defined before December. | Compliance and quality | File and plan B |
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What goes wrong
The eight most common mistakes
And a ninth that is not about interpretation: leaving it to a single person. The file touches procurement, quality, IT and management.
Confusing postponement with repeal
The application date moved; the regulation was not withdrawn. The text in force dates from June 2023.
Treating low risk as an exemption
Low risk still means geolocation, proof of legality and a declaration.
Forgetting that exports are covered
Shipping a product out of the EU triggers the same obligations as bringing it in.
Treating wooden packaging as an in-scope product
Support packaging is out. The paper or cardboard product you sell is not.
Not keeping the reference numbers you receive
For a downstream operator, that number is compliance. Without a field in the ERP, it gets lost.
Not keeping documentation for five years
Including the evidence behind the risk assessment, not just the declaration.
Relying on a sustainability certificate
It supports the risk assessment. It does not replace due diligence or geolocation.
Waiting for the IT system
The system is already open. Every week without tests is a week without knowing which data you lack.
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Why Dcycle
Collecting EUDR data by email or with Dcycle
What changes in step 1 of due diligence, the one that takes longest.
| Email and Excel | With Dcycle | |
|---|---|---|
| Requesting the data | One email and one template per supplier | One questionnaire sent to everyone at once |
| Knowing who has replied | Checking the inbox | Status and counter per supplier |
| Certificates and documents | Attachments scattered across emails | Uploaded by the supplier in the portal |
| Effort for the supplier | A different format per customer | Free portal, no licence |
| Interpreting the regulation | On your own | With Dcycle's expert team |
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FAQ
Frequently asked questions about the EUDR
What is the EUDR?
The EUDR is Regulation (EU) 2023/1115 on deforestation-free products. It requires proof that certain products placed on the EU market, made available within it or exported from it do not come from land deforested after 31 December 2020 and were produced in line with the laws of the country of origin. It covers seven commodities (cattle, cocoa, coffee, oil palm, rubber, soy and wood) and their derived products by HS code, and is met through a documented due diligence procedure and a declaration in the Commission's information system.
When does the EUDR apply?
From 30 December 2026 for medium and large companies, and for micro and small companies in the timber sector. From 30 June 2027 for all other micro and small enterprises. And from 30 December 2027 for the new Annex I entries.
Will the EUDR be postponed again?
The two previous delays were approved with the information system unfinished and the guidance unpublished. In 2026 both are done: the system reopened at the end of June and the updated guidance was adopted on 13 July in every EU language.
Which products does the EUDR cover?
Seven commodities (cattle, cocoa, coffee, oil palm, rubber, soy and wood) and their derived products identified by HS code. The list of commodities has not changed since 2023; the list of Annex I codes has.
What left the scope in July 2026?
Bovine hides and leather (4101, 4104, 4107), retreaded tyres and soy for sowing. Printed products in chapter 49 had already left with the December 2025 reform.
What came into scope?
Instant coffee, certain palm oil derivatives and frozen bovine tongues, applicable from 30 December 2027.
What is a downstream operator?
It is the role created by the December 2025 reform. It does not repeat the first link's due diligence or submit its own DDS: it collects, keeps and passes downstream the reference number of the initial declaration.
Does the EUDR affect me if I only export from the EU?
Yes. Exporting from the Union triggers the same obligations as placing on the market. It is the most common scope mistake in supply chains.
If my supplier is in a low-risk country, am I exempt?
No. Low risk spares you the formal risk assessment and mitigation measures, but plot geolocation, proof of legality at origin and the declaration still have to be done.
Is my supplier's sustainability certificate enough?
It does not replace due diligence. It can support the risk assessment as evidence, but it does not replace information gathering, geolocation, proof of legality or the declaration.
What are the sanctions for breaching the EUDR?
A fine of at least 4% of annual turnover in the Union, confiscation of the products concerned and the revenue earned from them, and exclusion from public procurement and access to public funding (Art. 25).
Who enforces the EUDR?
The competent authority designated by each member state, with customs and market surveillance bodies carrying out much of the checks on the ground.
How long must EUDR documentation be kept?
Five years. That includes declarations, reference numbers received and the evidence behind the risk assessment, not just the declaration.
Does Dcycle have an EUDR module?
The dedicated EUDR module is listed as "coming soon" in Dcycle's framework marketplace. Today Dcycle sends the questionnaire to your suppliers, collects their responses and documents in the portal and shows you who has replied; Dcycle's expert team supports you with the risk assessment and in preparing the declaration. The declaration itself is submitted in the Commission's information system.
What does Dcycle add compared with spreadsheets and email?
In the step that takes longest, collecting data from suppliers: a single send of the questionnaire to all of them, a free portal where the supplier answers and uploads certificates, and the status of every response in view. No chasing Excel versions by email or rebuilding who sent what.
Can I use the same suppliers for CSRD, carbon footprint or EcoVadis?
Yes. Your suppliers live on the same platform as your other Dcycle projects, so you do not set them up twice and you can send them other questionnaires from the same place.
30-minute demo
Bring your products and suppliers and we will go through them with you
We review your scope matrix by HS code, confirm your role in the chain and show you how to send the questionnaire to your suppliers from Dcycle.
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